EVELYN PARTNERS ASSET MANAGEMENT LIMITED

EVELYN PARTNERS ASSET MANAGEMENT LIMITED 1. Cover Page EVELYN PARTNERS ASSET MANAGEMENT LIMITED 45 Gresham Street London, EC2V 7BG United Kingdom https://usa.evelyn.com/evelyn-partners-usa/ Part 2A of Form ADV: Firm Brochure November 10, 2025 This Firm Brochure (the “Brochure”) provides information about the qualifications and business practices of Evelyn Partners Asset Management Limited (“Evelyn Partners” or the “Firm”). If you have any questions about the contents of this brochure, please contact by telephone at +44 203 8186930 or by email at us.services@evelyn.com.The information in this Brochure has not been approved or verified by the United States Securities & Exchange Commission (the “SEC”) or by any state securities authority. Evelyn Partners is an investment adviser registered with the SEC under the Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated Page 1  EVELYN PARTNERS ASSET MANAGEMENT LIMITED 2. Material changes The purpose of this page is to inform you of any material changes since the previous version of this brochure i.e. March 2025. Item 10 has been updated to reflect the removal of Evelyn Partners Fund Solutions Limited, Evelyn Partners LLP and Evelyn Partners Corporate Finance Limited, as the entities have been sold and hence are no longer part of the Group. Furthermore, Andrew Baddeley, Group Chief Financial Officer, and Scott Kirk, Group Chief Financial Officer (interim), have left Evelyn Partners (9th April 2025 and 30th June 2025 respectively) and have been replaced by Alex Gersh, Chief Financial Officer, from 27 June 2025. Sally Boyle became the Chair of the Remuneration Committee from 1 May 2025. Sean Hagerty has been appointed as a new Independent Non-Executive Director from 1 May 2025. Keith Jones, Independent Non-Executive Director, left on 5 September 2025. We will review and update our brochure at least annually to make sure that it remains current. Page 2  EVELYN PARTNERS ASSET MANAGEMENT LIMITED 3. Table of Contents 1. Cover Page 1 2. Material Changes 2 3. Table of Contents 3 4. Advisory Business 4 5. Fees and Compensation 4 6. Performance based fees and side-by-side management 5 7. Types of Clients 5 8. Methods of analysis, investment strategies, and risk of loss 5 9. Disciplinary information 6 10. Other Financial Industry activities and affiliations 6 11. Code of ethics, participation or interest in client transactions and personal trading 8 12. Brokerage practices 8 13. Review of Accounts 9 14. Client Referrals and Other Compensation 9 15. Custody 9 16. Investment discretion 10 17. Voting Client securities 10 18. Financial information 10 Page 3  EVELYN PARTNERS ASSET MANAGEMENT LIMITED 4. Advisory business Evelyn Partners Asset Management Limited (EPAM) (“We”, “Us”, “Evelyn Partners”, “EPAM” or the “Firm”) is a United Kingdom (“UK”) based wealth Management Company which is a wholly owned subsidiary of Evelyn Partners Group Limited. The ultimate parent companies are Platinum LP. Guernsey Limited and Whitman Limited Partner LP (Cayman Islands). Evelyn Partners provides discretionary investment management services across a broad range of client account types, including (where eligible) investment portfolios, retirement accounts, personal pensions, trust and charity accounts and insurance company accounts. The Discretionary Portfolio Service (DPS) allows for the purchase and sale of specific securities and can, in some circumstances, allow for you to impose certain restrictions; meaning we will not purchase any securities which, for any reason, you may not be comfortable holding. As of 31 December 2024, the Firm managed approximately $1,213,158,729 USD in regulatory assets under management, with $1,208,382,837 managed on a discretionary basis, and $4,775,892 managed on a non-discretionary basis. In this document “’Client’ means all clients of the Firm and consists of any entity or natural person to which the Firm provides investment advisory or management services, including each Private Investment Fund and all managed account clients.” 5. Fees and compensation Our charges are levied based on the value of the assets that our clients entrust us to manage. We will charge our clients on a tiered basis which means that our percentage investment management fee will decrease as your assets increase. There are three principal sources of cost to clients resulting from investment management: 1. Our fee for managing the portfolio 2. The underlying investment management fees of any funds that we choose to hold 3. Custodian charges from Pershing Advisor Solutions LLC. The above 1-3 are further outlined below. a. Evelyn Partners Management Fee The annual fee for our investment management services would be a tiered fee as below: Portfolio Value Investment Management Fee (% of assets) Up to £250,000 (or USD equivalent) 1.25% Next £250,000 (or USD equivalent) 1.10% Next £2,000,000 (or USD equivalent) 0.90% Above £2,500,000 (or USD equivalent) 0.55% These fees are deducted from Client’s Assets on a quarterly basis. We do not charge any fees for transactions, however there are transaction fees levied by our custodian Pershing (see “Custodian Charges” below). EPAM also uses other custodians. Further details, including fees, are available on request. b. Underlying Fund Costs The Ongoing Charges Figure (“OCF”) of the underlying funds ** that we would hold in the portfolio is currently 0.15% per annum. The ongoing third party* transitional charges have been estimated at an additional cost of 0.03% per annum, based upon a $250,000 portfolio. Page 4  EVELYN PARTNERS ASSET MANAGEMENT LIMITED *The fund costs are based on a portfolio using our current holdings for Strategy 3, which is appropriate for an investor who is comfortable with low volatility of returns, typically having around 40% of their portfolio invested in equities, and who is able to tolerate a loss of up to 12.5% of the value of their portfolio in any one year. This percentage loss is based on what might be reasonably expected 95% of the time. The projected annualised rate of return over the longer term is the Consumer Price Index (CPI) +1.5%. **The external managers of the underlying funds held within the portfolio will levy an annual charge known as the Ongoing Charges Figure (“OCF”) to cover their management costs. In addition to this there are also Fund Transaction Costs which are the charges paid by a Fund Manager when buying and selling the underlying investments in their fund, including taxes, custodial fees and broker commission. Both these costs are built into the price of the funds, and you are not charged these costs directly. c. Custodian Charges We do not charge any fees for transactions, however there are transaction fees levied by our custodian Pershing Advisor Solutions LLC. The main costs from Pershing are shown below: • US Stocks $10 flat ticket charge up to 3,000 shares. Each additional share over 3,000 will be charged at $0.01 per share. • US Mutual Funds $25 per transaction • Non-US Stocks 25 basis points subject to a $25 minimum charge plus a foreign settlement fee* • Cash transfers $20 for transferring money out of your account • Legal stock transfers $40 per transfer • Account termination $100 per account *Please note that for non-US stocks, we will aim to buy cost-effective, US-listed versions of these companies where possible, such as American Depositary Receipts (“ADRs”). These are securities that trade in U.S. financial markets that represent the securities of non-U.S. companies. The costs would therefore be associated with US stocks as opposed to the higher costs incurred by buying the non-U.S. stocks directly in foreign markets. EPAM also uses other custodians. Further details, including fees, are available on request. 6. Performance-based fees and side-by-side management Evelyn Partners does not charge performance-based fees. 7. Types of clients Evelyn Partners can generally provide investment management services to high-net-worth individuals and families, companies, charities, trusts, private funds and financial intermediaries on a discretionary basis. Our minimum account size is £250,000 or the USD equivalent. 8. Methods of analysis, investment strategies and risk of loss Our investment process is based on the principle that asset allocation will be the primary determinant of long-term investment performance. Each portfolio is run within a specific risk profile to which an asset allocation will be assigned with the goal of maintaining the appropriate long-term risk reward parameters that have been agreed with the client. The appropriate asset allocation at any given time will be determined by the quantitative and qualitative output of our investment process, considering such factors as: • Medium and Long-term economic trends. Page 5  EVELYN PARTNERS ASSET MANAGEMENT LIMITED • Correlation across the asset classes. • Potential of return relative to cash, risk and inflation. • Time horizons to filter short term noise in favour of long-term compounding. We expect equities to be the main driver of returns within portfolios, preferring a small, focused portfolio. Other areas of focus are: • Consistent return on investment capital. • Relatively stable top line and high gross margins. • Predictable and robust cash flows. • Strong balance sheets. • Good management of brands. • Generation of free cash flow. • Consistent dividend record. We also consider the effects of frictional costs within portfolios such as dealing costs, management fees and taxation. The material risks of investing in our portfolios include: • Market Risk – Arises mainly from uncertainty about future prices of securities. It represents the potential loss the portfolio might suffer through holding market positions in the face of price movements. Evelyn Partners Practitioners will manage market price risk on a daily basis in accordance with the investment objectives and mandate guidelines. • Inflation Risk – The value of your investment will be affected by inflation. Unless the performance of an investment meets or exceeds the rate of inflation, the real value of that investment will reduce. • Interest Rate Risk – Interest rate risk represents the potential losses that the strategy may suffer due to adverse movements in relevant interest rates. The amount of income receivable from bank balances will be affected by fluctuations in interest rates. • Credit Risk – Credit risk is the risk that counterparties, or investment issuers will be unable or unwilling to meet a commitment that they have entered into and potentially result in financial loss. The strategy will be exposed to settlement risk on parties with whom it trades and custody risk. In managing this risk, Evelyn Partners seeks to work with and / or invest in institutions that are well known, financially sound and where appropriate well rated by rating agencies. • Settlement Risk – Default by a broker could expose the strategy to an adverse price movement in the security between execution and settlement. When carrying out transactions in listed securities these are settled on cash versus delivery basis. • Currency Risk – Currency risk is the risk that the value of financial instruments will fluctuate due to changes in foreign exchange rates. Currency risk is addressed by the Investment Manager buying predominantly global businesses with a well-diversified currency profile. The currency exposure of cash holdings is actively managed on a regular basis. Note: All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends and other distributions), and the loss of future earnings. Although we manage the assets in a manner consistent with risk tolerances, there can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of loss. 9. Disciplinary information Evelyn Partners has no material legal or disciplinary events to disclose. 10. Other financial industry activities and affiliations EPAM is not registered with FINRA and does not have any pending applications with any other broker-dealers or registered representative of broker-dealers outside of the Evelyn Partners Group. Page 6  EVELYN PARTNERS ASSET MANAGEMENT LIMITED Our employees and management are not registered with the Commodity Futures Trading Commission (CFTC) and do not have any pending applications as a futures commissions merchant, commodity pool operator or commodity trading advisor. The Evelyn Partners Group has a number of Regulated Entities; however, it is only EPAM which is regulated by the SEC, and which provides products and services to US Persons. Type of Business Entity name Authorization status Broker-Dealer FCA Regulated Evelyn Partners Investment Services Limited Other Investment Adviser Evelyn Partners Securities FCA Regulated Other Investment Adviser FCA Regulated Evelyn Partners Investment Management LLP Other Investment Adviser FCA Regulated Evelyn Partners Investment Management Services Limited Other Investment Adviser Evelyn Partners Asset Management Limited SEC & FCA Regulated Evelyn Partners Global IDF GP Limited N/A Other Investment Adviser and sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Other Investment Adviser FCA Regulated Evelyn Partners Discretionary Investment Management Limited FCA Regulated Other Investment Adviser Tilney Discretionary Portfolio Management Limited Dart Capital Limited FCA Regulated Other Investment Adviser Other Investment Adviser Evelyn Partners Investment Management (Europe) Limited Central Bank of Ireland (CBI) Regulated Other Investment Adviser Evelyn Partners International Limited Jersey Financial Services Commission (JFSC) Regulated Evelyn Partners Financial Planning Limited FCA Regulated Other Investment Adviser Evelyn Partners Financial Services Limited FCA Regulated Other Investment Adviser HFS Milbourne Financial Services Limited FCA Regulated Other Investment Adviser HW Financial Services Limited FCA Regulated Other Investment Adviser In line with its corporate governance framework, the Evelyn Partners Board maintains overall responsibility for the management of the Group, including ultimate oversight of Evelyn Partners Group Limited and its subsidiaries’ (including the Firm) operations. In addition the Board is responsible for ensuring that there is a competent and prudent management team; sound planning process; a strong and effective system of internal control; adequate accounting and other records; compliance with appropriate statutory regulatory obligations; a comprehensive set of management information to enable effective oversight, challenge and decision making; an embedded set of values and ethics; and a robust process for monitoring progress against strategic objectives and plans. The Firm is part of the Evelyn Partners Group Board. The Firm Board members are as follows: • Chris Grigg – Non-Executive Chairman and Chair of the Nominations Committee • Carla Stent – Independent Non-Executive Director and Chair of the Risk & Audit Committee • Chris Pell – Non-Executive Director (representing Permira Funds) Page 7  EVELYN PARTNERS ASSET MANAGEMENT LIMITED • Thibault Huysseune – Non-Executive Director (representing Permira Funds) • Peter Deming – Non-Executive Director (representing Warburg Pincus) • Paul Geddes – Chief Executive Officer Evelyn Partners Group Limited and its solo-regulated subsidiaries • Kjersti Wiklund – Independent Non-Executive Director • Sally Boyle – Independent Non-Executive Director and Chair of the Remuneration Committee • Alex Gersh - Chief Financial Officer Evelyn Partners Group Limited and its solo regulated subsidiaries • Sean Hagerty – Independent Non-Executive Director. 11. Code of ethics, participation or interest in client transactions and personal trading The following is a summary of Evelyn Partners’ Code of Ethics and Personal Securities Transactions Policy (the “Code” or “Code of Ethics”) which has been adopted in accordance with Section 204A-1 of the Investment Advisers Act of 1940 (the “Advisers Act”). A full copy of the Code is available to any client or prospective client upon request and without charge. Evelyn Partners has adopted a Code of Ethics which applies to access persons of the Firm and any other person the Chief Compliance Officer (“CCO”) deems appropriate. • The foundation of the Code of Ethics is based on the underlying principles that: Employees must comply with relevant securities regulations. • Employees must at all times place the interests of the Firm’s clients first. • Employees must make sure that all personal securities transactions are conducted consistent with the Code and Personal Account Dealing Policy. • Employees must report any violation of the Code of Ethics. • Employees should not take advantage of their position at Evelyn Partners Asset Management Limited. Evelyn Partners’ Access Persons are required to adhere to the Code of Ethics and certify their adherence to the Code upon commencing their employment and on an annual basis thereafter. Furthermore, all Access Persons are required to deliver to the CCO, or the delegated compliance function, a detailed report of personal transactions (covering substantially all securities other than exempted securities) undertaken during each calendar quarter. Information in respect of any new brokerage accounts opened during the relevant period is also required to be disclosed. Personal trading: From time to time, employees (and certain related persons) may have an interest in securities which are owned by clients of Evelyn Partners. In such circumstances, the Firm has policies in place to ensure that the interests of the Firm’s employees do not conflict with the obligations the Firm owes to its clients. All Access Persons must obtain pre-clearance from the CCO or a delegated compliance function for all personal trades in designated securities and also obtain pre-approval from the CCO, or the delegated compliance function, before engaging in any outside business activities or applying for an allocation of an Initial Public Offering (“IPO”) or private placement. Conflicts of interest- It is the policy of the Firm that all employees and others working on its behalf act in good faith and in the best interests of the Firm and its clients. The Firm has Policies and Procedures in place to identify and manage conflicts of interest. Code Violations -The Firm takes any violation of the Code of Ethics seriously and will take appropriate action where necessary. 12. Brokerage practices Evelyn Partners has full discretionary authority over Client Accounts, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. Evelyn Partners’ authority is limited by its own internal policies and procedures and investment guidelines. Page 8  EVELYN PARTNERS ASSET MANAGEMENT LIMITED In selecting an appropriate broker-dealer to affect a client trade, Evelyn Partners seeks to obtain “best execution,” meaning that the Firm will execute a securities transaction for a client in such a manner that a client’s total costs or proceeds in the transaction are most favourable under the circumstances. Accordingly, in seeking best execution, Evelyn Partners takes into consideration the price of a security offered by the broker-dealer, as well as a broker-dealers’ full range and quality of their services including, among other things, their facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to Evelyn Partners instructions and requests, brokerage and research services provided to Evelyn Partners (e.g., research ideas, analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. Aggregation of Orders - We may aggregate trade orders for the Client Accounts to achieve more efficient execution or to provide for equitable treatment among accounts. Client Accounts participating in aggregated trades will be allocated securities based on the average price achieved for such trades. Client Accounts will have an account with the relevant custodian. Soft Dollars - Evelyn Partners does not and has no intention to use “soft dollars” generated by our clients’ trading activities to purchase research services or products that would otherwise have been an expense of the Firm. Trade Errors - The Firm's traders may on occasion experience errors with respect to trades made on behalf of the Client. Trade errors can result from a variety of situations, including for example, when the wrong security is purchased or sold, when the correct security is purchased or sold but for the wrong account, when the wrong amount is purchased or sold (e.g., 1,000 shares instead of 10,000 shares are traded), or when a misallocation among the Accounts occurs. The Firm endeavours to detect trade errors prior to settlement and correct them in an expeditious manner. 13. Review of accounts Each portfolio that Evelyn Partners manages is subject to a review. These reviews are designed to ensure that all accounts remain within the Firm’s investment guidelines agreed with each client comparing the Clients Accounts’ performance to their stated goals. In addition, all clients will receive a periodic review where the Clients situation and goals are discussed along with the performance of the portfolio. The client will receive statements regarding their account, its holdings, transactions and fees at least quarterly from the Firm and / or Pershing Securities Limited or Pershing Advisor Solutions LLC. 14. Client referrals and other compensation Evelyn Partners is not remunerated by any party other than its clients. The Firm does not currently utilize third party marketing firms for its U.S. clients. 15. Custody Advisers with custody of client funds and securities must maintain them with “Qualified Custodians.” “Qualified Custodians” under the amended rule include banks and savings associations and registered broker-dealers. Evelyn Partners does not maintain direct custody or possession of any of its client’s funds or securities. However, as client fees due to EPAM are deducted directly from our clients’ accounts EPAM is deemed to have sufficient custody and control of client assets pursuant to Rule 206(4)-2 of the Advisers Act. Evelyn Partners or the relevant custodian will at least quarterly send a client statement to the client as well as annually sending the Privacy Notice and ADV Part 2. 16. Investment discretion EPAM has full discretionary authority to manage the discretionary Client Accounts, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. Page 9  EVELYN PARTNERS ASSET MANAGEMENT LIMITED 17. Voting client securities Evelyn Partners will be notified of any action (which requires voting by the security holder) by the relevant Custodian. Evelyn Partners will exercise any vote on your behalf and will always seek to vote in a manner that we determine to be in your best interests. We maintain written records of the proxy vote on each occasion a proxy is voted. Information on Evelyn Partners’ Proxy Voting Policy and how the Firm has voted a particular client proxy is available upon request. Where any material conflict is identified, the matter will be referred to the CCO for input on how best to proceed 18. Financial information Evelyn Partners has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Page 10